As Jersey continues to make preparations for its first National Risk Assessment, there is a recognition that changes are required to the SAR template amongst other areas to improve the quality and standard of submissions to the FIU. Part of these changes require the FIU to assist industry in the preparation of SARS. To that […]

Clashes between the need for secrecy in dealing with potential criminality and the obligations of transparency under data protection legislation are common. A recent UK decision (Lonsdale –vNational Westminister Bank Plc) highlights one such clash. In particular, it considered what happens when a DSAR (a Data Subject Access Request) is made seeking disclosure of SARs […]

Natalie Mayflower Sours Edwards Illegally Photographed SARs and Other Sensitive Government Information and Transmitted Them To Reporter In Connection With Approximately 12 News Articles Over 1-Year Period Geoffrey S. Berman, the United States Attorney for the Southern District of New York, William F. Sweeney Jr., Assistant Director-in-Charge of the New York Division of the Federal […]

Anti-money laundering laws should be streamlined and strengthened to help law enforcement agencies to focus on serious crime, say the Law Commission. Money laundering is estimated to cost every household in the UK £255 a year and allows criminals to profit from their crimes. It is widespread, with between 0.7 and 1.28% of annual European […]

Swiss banks step up SARS on Saudi clients Following reports about • the arrest last month of more than 200 people, including some of Saudi Arabia’s richest businessmen and princes. They were detained at the Ritz-Carlton hotel in Riyadh as part of an anti-graft operation launched by Crown Prince Mohammed bin Salman, the kingdom’s powerful […]

Earlier this year the UK tightened its anti-money laundering regime with the passage of the Criminal Finances Act 2017 (“the Act”). Businesses have until the end of this month to comply. The new legislation Overhauls suspicious activity reporting, provides law enforcement with new powers to investigate and seize property and creates a new corporate “failure […]

SRA v Susan Anita Barrington-Binns Summary: Susan Anita Barrington-Binns [The respondent] failed to be alert to suspicious features of a transaction in which she facilitated the payment of £1,269,725 through her client account to an offshore bank account in Belize and failed to have sufficient regard to her duties under the MLRs. The respondent failed […]

In the case of National Crime Agency v N and Royal Bank of Scotland plc [2017] EWCA Civ 253, the Court of Appeal allowed the appeal of the National Crime Agency (NCA) against orders for a bank to execute customer transactions, without consent from the NCA, when the bank had made suspicious activity reports on […]